EPA Clarifies Monsanto Refillable Containers with a Q and A, October 2011.After a lot of research about DOT's regulations and a number of discussions with Monsanto, here are two Q&As to provide some clarity about why Monsanto's refillable containers (with capacities of 120 gallons or larger) can be used in compliance with EPA's pesticide container regulations even though they do not have the DOT/UN marking and why they do not need to be leakproofness tested. These Q&As have been reviewed by Monsanto, EPA, and DOT.Q & A document

Aginfodata has come up with a "Good Practice Labeling Guide" for the new Pesticide Container and Containment (PCC) Rules that became effective August 16, 2011.Good Practice Labeling Guide